Sharing Participant Stories: A Guide to CMS PACE Marketing Guidelines
Participant stories are a powerful way to showcase the life-changing impact of PACE (The Program of All-inclusive Care for the Elderly). They help illustrate the benefits of PACE services in a relatable, inspiring manner while fostering trust with prospective participants and their families. However, it’s crucial to ensure these stories comply with CMS PACE Marketing Guidelines when shared publicly.
We are not lawyers, consult your counsel, this is not legal advice, etc.
1. Are Participant Stories Considered Marketing Materials?
Participant stories are classified as marketing materials if they:
- Promote enrollment in PACE.
- Describe PACE benefits or services in a way that could influence prospective participants’ decisions.
Why Participant Stories Often Qualify as Marketing:
- Highlight PACE Benefits: Stories frequently describe services such as medical coordination, home care, physical therapy, and social engagement. These are clear descriptions of PACE benefits.
- Relevant CMS Guideline: Section 20.1 – PACE Program Information.
- Tied to Enrollment: Statements like “If Aaron hadn’t enrolled, his mobility would have continued declining, potentially leading to institutionalization” connect positive outcomes directly to enrollment in PACE.
- Relevant CMS Guideline: Section 30.1 – Marketing Review Process.
Because of these elements, most participant stories shared publicly fall under the category of marketing materials and require careful compliance with CMS rules.
2. Do Participant Stories Require CMS Approval?
Yes, participant stories must be submitted to CMS for review and approval if they are:
- Shared on public platforms like flyers, brochures, websites, or social media, or
- Designed to highlight participant outcomes or promote PACE services and enrollment (even in a non-public "enrollment package").
Reference to the specific CMS requirements for participant stories:
- Section 30.1 – Marketing Review Process.
- Section 50.4 – Product Endorsements/Testimonials.
3. Exceptions: When Stories May Not Need Approval
In rare cases, participant stories might not require CMS approval if:
- They are shared exclusively with current participants or their caregivers (e.g., internal newsletters).
- They are framed in a purely educational way and do not describe PACE benefits or encourage enrollment.
- See: Section 80 – Materials Not Subject to Marketing Review.
However, because participant stories shared by PACE organizations often inherently tie outcomes to PACE services, such exceptions are uncommon.
3 Steps for Compliant Testimonials
To use participant stories effectively while adhering to CMS guidelines:
- Get written consent, and keep it on file. Your Director of Marketing should maintain an electronic file on your PACE organization's storage driver for consents (for testimonials, photographs, etc.)
- Avoid exaggerated stories or inaccurate testimonials -- even if provided by a participant or caregiver.
- Submit through your HPMS system. You'll be notified if it's not approved; and if you don't hear back within 45 days, it's ok to use.
Why Compliance Matters
By following these guidelines, PACE organizations can use participant stories to inspire and inform while maintaining trust, ethical standards, and regulatory compliance.
CMS is getting increasingly strict about marketing of Medicare and Medicaid benefits.
If you have questions about using participant stories or need assistance preparing materials for CMS submission, ask your ED or compliance director.
Sharing participant stories is a way to connect with prospective participants and show how PACE makes a difference. With careful planning and compliance, these stories can shine a light on the life-changing support PACE provides.